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Table of Contents
On September 21, the North Carolina Libertarian Party sued in state court, alleging that the state constitutional provision that "Elections shall be free" requires the state to set easier ballot access laws. Libít. Party of N.C. v Bd. of Elections, Wake Superior Ct., 05cvs-13073. The case will move fast, since the party has candidates in city elections this November.
On September 26, the Court denied the partyís request to hold a primary in Charlotte on September 27. The party will now choose a candidate by private mail ballot, and will return to court in mid-October seeking a preliminary injunction to get its candidates on the November 2005 ballot.
North Carolina requires 69,734 signatures to put a new party on the ballot, and then removes it if it fails to poll 10% for president or governor. The combination of a high petition requirement, plus a high vote requirement, is deadly. If a party just had to get 69,734 signatures once, some parties could do this. But to expect them to do it over and over is another matter. The Reform Party spent $250,000 in 2000 to qualify in North Carolina.
On September 19, the Charlotte Observer titled an editorial, "Closed elections. State Makes it Too Hard for Third Parties to get on Ballot."
On September 24, the Jacksonville Daily News agreed, saying, "This past legislative session, lawmakers had the opportunity to change the law to make it easier for smaller parties to gain ballot access. But the Democrats and Republicans holding leadership positions werenít about to let the proposal see the light of day."
Bills to ease ballot access have had these results during the last 16 years:
Ballot access lawsuits filed by minor parties, alleging that the State Constitution requires tolerant ballot access, have won in Alaska, Maryland and Michigan. In each case the laws had been upheld by federal courts, yet were overturned by state courts.
Recent editorials in the Durham Herald-Sun, the Greenville Daily Reflector, the Henderson Dispatch, and the Washington Daily New, also support the lawsuit. So do Common Cause and the League of Women Voters.
The lawsuit will be helped by evidence that when North Carolina ballot access laws were lenient, no problem with ballot crowding occurred. North Carolina only required 10,000 signatures between 1929 and 1981, and never had a ballot with more than six parties on the ballot. Also, in the past, the vote test for a party to remain on was 3%, not 10%.
Another fact helping the lawsuit is that the Libertarian Party had 13,006 registered members until last month, when the State Board of Elections decertified the party and forcibly converted all the partyís members to independents. Libertarian registration in North Carolina was larger than it had ever been. Also, it was the largest minor party registration total for any minor party anywhere in the south, except that Florida Libertarian registration is also 13,000.
On September 7, the New York State Supreme Court, Appellate Division, ruled that non-residents of a city must be permitted to circulate a city initiative petition. Bray v Masolais, 3rd jud. dept., 98777. Both state and federal courts in New York had already ruled that the First Amendment requires that circulators for candidates must be permitted to work outside their home legislative districts, and the Bray decision rests upon those rulings. The Bray case arose in Albany. Despite winning the lawsuit, the initiative failed to qualify.
An initiative is circulating in Massachusetts to legalize "fusion", as well as to make it easier for a party to remain on the ballot. "Fusion" means that two parties are jointly permitted to nominate the same candidate.
The initiative would amend the law on how a party remains on the ballot. Currently, if it has registration below 1% of the state total, it must poll 3% for any statewide race, every two years. The initiative would provide that the vote test would only need to be met once every four years. Itís fairly easy for a party to poll 3% in the mid-term years, since there are always five statewide state offices up. But itís not easy in presidential years, especially when no U.S. Senate race is on the ballot. For instance, in 2004, both the Green and Libertarian Parties were disqualified because neither could poll 3% for president.
The initiative needs 65,825 signatures by November 23. It is backed by the Working Families Party and several unions, and is likely to qualify. For more information, see MassBallotFreedom.com.
Two separate panels of the U.S. Court of Appeals, 6th circuit, are weighing cases over the constitutionality of Ohio ballot access petition deadlines. Hearings in both cases were held during September.
The New Party Petition Deadline
On September 14, a 3-judge panel of the 6th circuit heard Libertarian Party of Ohio v Blackwell, no. 04-4215. The main issue is the constitutionality of the Ohio law that requires a new party to submit its petitions an entire year before a general election.
The hearing was disappointing. One of the three judges zealously took the stateís position, and dominated the hearing. It appeared that none of the three judges were familiar with the Libertarian Partyís evidence and its written arguments.
It should not be difficult for any minor party to win a lawsuit against a law that requires a new party to qualify an entire year before a general election. Ohio is the only state with a deadline for new parties in the year before the election. No reported court decision has ever upheld a new party petition deadline earlier than April of an election year. However, when the attorney for the Libertarian Party pointed this out, one judge said, "Well, that doesnít mean we are bound by those precedents; we can be the first to uphold such a deadline!"
Ironically, the U.S. Supreme Court itself already ruled that Ohioís new party petition is too early. In Williams v Rhodes, the 1968 case that put George Wallaceís American Independent Party on the ballot, the U.S. Supreme Court said Ohioís deadline was "unreasonably early". At the time, the Ohio deadline was February of an election year, three months later than the current law.
In 1968, Ohio required a new party to submit a petition signed by 15% of the last gubernatorial vote. The American Independent Party managed to get this number of signatures.
The only barrier that kept the party off the ballot was that the party didnít submit them until July 1968, instead of the deadline in February. After the party submitted the signatures, which were rejected for being late, the party sued, and won Williams v Rhodes in the U.S. Supreme Court.
The basis for these conclusions about Williams v Rhodes can be found in the briefs of both sides in that case, and in the transcript of the oral argument in the U.S. Supreme Court. The 1968 decision itself does not make all these points as clear as they could be. The American Independent Party in the lawsuit had complained about theoretical difficulties in holding a primary, even if it had submitted the signatures on time. The party feared that no one could run in its primary, or vote in its primary, if they had voted in the Democratic or Republican primaries in 1966. But Ohioís Secretary of State took the position that these fears were groundless, and that he would have accommodated the party if it had just met the deadline.
After the election, Ohio lowered the number of signatures needed for a new party to 1% of the last presidential or gubernatorial vote, but didnít reform the deadline, and even made it earlier.
Ohio continues to defend its early deadline by saying that the state Constitution requires the state to provide a primary for each political party. Since Ohio holds its primary in presidential years in March, election administration concerns require the party to qualify by November of the year before.
In the current case, the Libertarian Party had presented evidence showing that Ohio did not require minor parties that appeared on its ballot to hold primaries between the onset of the primary (back in 1908) and 1947 (even though the State Constitution was the same on that point, during those years). Also, when courts had put the American Independent Party on the ballot in 1968, and the Socialist Labor Party on the ballot in 1970, no primaries had been held for those parties.
Also in 1976, the American Partyís petition was not validated until after the primary was over, and therefore it was permitted to nominate by convention. Finally, in 1996, when the Reform Party didnít qualify in time for its own primary, the state still permitted it to appear on the ballot (but for president only).
The Libertarian Party also presented evidence that, in U.S. history, new parties are usually founded in election years. The Republican Party was founded in July 6, 1854, in reaction to Congress having passed the Kansas-Nebraska Act in May 1854. The new party went on to win a plurality in the U.S. House of Representatives that fall.
The Peopleís Party was founded on February 22, 1892, at a mass meeting in St.. Louis called by twelve organizations. That fall, it went on to poll 10% of the presidential vote and to elect eleven members of the House.
Theodore Roosevelt called for the formation of his new Progressive Party on June 22, 1912, in Chicago. That party went on to place 2nd in the presidential race and to elect nine members of the House.
Henry Wallace announced the creation of his Progressive Party on December 29, 1947, in a radio broadcast and meeting in Chicago. Although he only polled 2% of the vote, his party won two U.S. House elections in 1948. No third party since then has elected anyone to the House.
None of these parties would have been able to get on the ballot in Ohio, if Ohioís current deadline has been in effect back then.
All of this evidence is in the record, but from the questions and comments made by the judges, it seemed most likely that none of them had read the record. Furthermore, the one judge who seemed zealous to uphold the law asked so many questions about the timing of election-administration related matters, the attorney for the Libertarian Party was unable to steer the argument around the points he wanted to make. Only fifteen minutes had been allotted for each side.
The judge who seemed zealously on the stateís side began a lengthy series of questions about the time needed to process a petition. He asked the attorney for the Libertarian Party, didnít the attorney agree that it probably takes 30 days for elections officials to check signatures? And if the petition was rejected, didnít the attorney agree that it would take 20 days for a lower court to settle the dispute? And didnít the attorney agree that if the lower courtís opinion were appealed, the mid-level court would take at least another 10 days? And didnít the attorney agree that a further appeal to the State Supreme Court would take at least 10 more days? And didnít the attorney agree that afterwards, when the issue was settled, elections officials would need at least 20 days to print the ballots? And didnít the attorney agree that absentee ballots must be mailed 30 days before the election?
All this is beside the point. Ohio law already sets a deadline of 75 days before the general election for an independent presidential candidate to submit a petition, so itís clear that all of these tasks can be managed with a petition deadline in late August.
If the Libertarian Partyís attorney had the opportunity, he might have mentioned these further points: five times, the U.S. Supreme Court has acted against early petition deadlines for minor parties and independent candidates, and that Court has never specifically upheld any particular deadline. Besides Williams v Rhodes, the U.S. Supreme Court struck down Ohioís March deadline for independent presidential candidates in 1983 in Anderson v Celebrezze. This decision is famous, and the panel knows about it. The U.S. Supreme Court also ruled in Mandel v Bradley in 1977 that when the historical record shows that few minor party or independent candidates qualify in a state with early petition deadlines, then that early deadline is probably unconstitutional. Mandel v Bradley is not a well-known case, but the panel surely knows about this case too, although it was not mentioned at oral argument.
What the panel didnít seem to have read, however, was the evidence showing that Ohio has had fewer minor parties on the ballot in the last 25 years than any other populous state. This evidence is crucial to applying Mandel v Bradley.
Finally, there are two instances at which the U.S. Supreme Court summarily affirmed lower court decisions that struck down early deadlines, and it is likely the panel is not aware of these two cases. One of them, Lendall v Jernigan, struck down an April petition deadline for independent candidates for the legislature in Arkansas. Lendall v Jernigan is especially important because the plaintiff-candidate in that case filed the lawsuit against the deadline before he had collected any signatures. Yet the 3-judge U.S. District Court in 1976 agreed that he had standing to challenge the deadline, and agreed with him that the deadline is unconstitutional. And the U.S. Supreme Court affirmed this decision, 433 US 901 (1977). Unfortunately, Lendall v Jernigan isnít reported, so itís not easy to document this precedent.
Still other points that never got raised were that 21 states have had early petition deadlines declared unconstitutional (Alabama, Alaska, Arkansas, Indiana, Kansas, Kentucky, Maine, Maryland, Massachusetts, Missouri, Nebraska, Nevada, New Jersey, North Carolina, North Dakota, Ohio, Pennsylvania, Rhode Island, South Carolina, South Dakota and Utah). In a few of these cases, it was so obvious that the deadlines were unconstitutional, that the states didnít even contest the lawsuits, but admitted their deadlines couldnít be defended.
Also, in Arkansas, Nebraska, Nevada, North Dakota and South Dakota, state laws required all new parties to nominate by primary. But lawsuits filed against the new party petition deadlines still won.
The other issue in the Libertarian Ohio case is whether it violates due process for the state to change the petition format in the middle of the partyís petition drive, and not tell the party about the new form. This point did not result in much discussion.
Independent Deadline Case
By coincidence, another panel of the 6th circuit last month heard the case against Ohioís March 1 deadline for independent candidates (for office other than president). Lawrence v Blackwell, no. 04-4022. The plaintiff-candidate, David Lawrence, had tried to run for the U.S. House last year using the independent candidate procedures. He was actually the nominee of the Socialist Equality Party, which did not attempt to gain political party status in Ohio. He had tried to file a declaration of candidacy on the deadline, but he was unable to obtain the needed 2,000 signatures until May 2004, too late. The U.S. District Court had upheld the March 1 deadline on the grounds that it would be unfair to the major parties if non-major party candidates could enter the race after the major parties had chosen their nominees.
The most riveting moment in the hearing came when the attorney for the Hamilton County Board of Elections acknowledged that there is no election administration-related reason to set the deadline so early. He said, "We could even handle it if the deadline were in September. We can even handle special elections called with only six weeks notice." The attorney for the county said the only justification for the March 1 deadline is fairness to the major party nominees.
An unspoken point is that the major parties control the state legislature, and if they donít like nominating so early in the election year, they are free to change the primary date. Another unspoken point is that if the Democrats and Republicans in the legislature really feel that it is unfair to let others jump into the race later, they could require a declaration of candidacy from independents on primary day, and provide that the petition is due later. This is the pattern used by Rhode Island, New Hampshire, Georgia and West Virginia, and for state office only in Kentucky.
Decisions in either case could come out at any time, but it would not be surprising if the decisions take at least six months.
California: SB 1050 passed the legislature on September 7. It legalizes write-in votes when the voter forgets to "X" the box next to the name written in. The Governor has until October 13 to sign or veto it.
Massachusetts: H77, to lower the number of signatures for a statewide minor party or independent candidate from 10,000 to 5,000, was heard on September 20 in the Joint Election Law Committee. Three witnesses testified for it, and none testified against it. The bill will probably be amended to ease the requirements for statewide primary ballot access as well.
Illinois: on September 7, the Attorney General ruled that towns are free to experiment with Ranked-Choice Voting if they wish. State law does not prohibit such experimentation.
Kentucky: this month, the Secretary of State will submit a proposed new regulation, directing elections officials to start keeping a tally of voters who register in active (but unqualified) minor parties.
Oregon: the Secretary of State has asked the Attorney General to rule on independent candidate petitions. Earlier this year, the legislature passed HB 2614, which says that no voter may vote in the primary and sign an independent candidate petition. However, since it is legal to circulate an independent candidate petition before the primary, the new law raises a question. What should be done if a voter signs an independent petition before the primary, and then tries to vote in the primary?
Arizona: on July 12, the Arizona Supreme Court ruled that state campaign finance law does not prevent a political party from receiving donations from corporations and labor unions (unless the money is earmarked for a particular candidate). Arizona State Democratic Party v State, 115 P.3d 121.
California: on August 25, the 9th circuit upheld a regulation that permits non-partisan groups like the League of Women Voters to register voters inside a Veterans Hospital, but does not permit partisan groups to do the same. Preminger and Santa Clara Democratic Central Committee v Principi, 04-16981.
Georgia: on September 19, the ACLU filed a federal lawsuit against the stateís new law, requiring every voter who votes at the polls to show a Georgia drivers license or a state identification card. Common Cause v Billups, no. 4:05-cv-201, n.d., Rome. A Georgia ID card costs $20. The requirement appears to conflict with the 24th amendment to the Constitution, which forbids imposition of any tax on voters. Georgia says it will waive the fee for indigents, but the 24th amendment does not just cover indigent voters; it covers all voters.
Iowa: on September 15, the Libertarian and Green Parties filed a lawsuit against the stateís voter registration rules, which force all voters to register "Republican", "Democratic", or "independent". Iowa and Kansas are the only states that donít have a blank line on the "political party" question on the voter registration form. Iowa Libertarian Party v Culver, 4:05cv-521. The ACLU filed this case.
New Mexico: on August 29, the State Supreme Court held arguments in the 2004 presidential recount lawsuit. Cobb v Canvassing Board, no. 29095. David Cobb and Michael Badnarik had applied for a recount last year, and paid the deposit of $114,400. The state refused to recount the votes, and in early 2005 the legislature increased the fee for a recount by a factor of ten.
New York: the 2nd circuit will hear Ulrich v Mane, no. 05-4560, in late December 2005 or January 2006. This is the challenge to state law that requires Republicans to submit 7,500 signatures in order to get on the primary ballot for citywide office in New York city. The signatures must be collected in 37 days, and there are only 440,000 registered Republicans eligible to sign.
Ohio: on September 9, a State Court of Appeals refused to remove four initiatives from the November 2005 ballot, even though the signatures were obtained partly by out-of-state circulators. State ex rel Finan v Blackwell, 05ap-854, 10th dist. This is good news for Ralph Naderís pending lawsuit in the 6th circuit, against an Ohio law that says out-of-state circulators for independent candidates are forbidden. That case is Blankenship v Blackwell, 04-4259.
Ohio (2): the federal case over whether the stateís presidential recount was conducted properly will go to trial in August 2006. Rios v Blackwell, 3:04cv-7724, n.d., Toledo.
Oklahoma: the pre-trial conference in the Libertarian Partyís lawsuit against the stateís ballot access laws for minor parties has been postponed from early September to late December, at the stateís request. Libertarian Political Organization v Clingman, 2004-2949, Oklahoma Co. Dist. Ct.
Virginia: a federal court held a hearing in Miller v Brown, 3:05cv-266, on September 14. The issue is whether the Republican Party may enforce a bylaw, prohibiting voters from voting in its primary if they have voted in a Democratic primary during the last 5 years (unless they sign a statement of loyalty to the Republican Party). Most of the argument focuses on whether the lawsuit can be heard this early, since the Republican bylaw wouldnít affect any election until 2007.
Washington: on August 27, a State Appeals Court invalidated a state law that makes it a crime for a candidate to make a false statement about his or her opponent. Rickert v State, 32274-9-II. The candidate who was being fined, Marilou Rickert, was a Green Party nominee for state legislature in 2002. Her campaign material had said that her Democratic opponent had voted to close a state facility, when actually he had voted against closing it. The court said, "We hold that the statute violates the 1st amendment of the U.S. Constitution because it does not require that the candidate be damaged by the false statements."
Edwards is a political science professor at Texas A&M University. His book argues that a direct popular election, with no run-off, is the best way for the U.S. to elect a president.
At least four books were published last year on the electoral college (see the Sep. 1, 2005 B.A.N. for a review of After the People Vote). This is the only one of these four books that opposes the electoral college, and it will probably become the leading book for anti-electoral college activists. It is a persuasive book, because it presents detailed, fact-based analysis to rebut the claims generally made by supporters of the electoral college.
The book is marred by some factual errors. In an attempt to make the electoral college seem even worse than it is, Edwards claims that Richard Nixon received more popular votes in 1960 than John Kennedy did. And for the 1800 election, he says, "Had there been no electoral college, John Adams would have won reelection in 1800" over Thomas Jefferson.
Edwards, in these passages, is saying that the electoral college has resulted in the election of the candidate who placed second in the popular vote in six elections, not just four (everyone agrees that the electoral college operated this way in 1824, 1876, 1888 and 2000).
However, his claim about 1800 is wrong. Edwards says the popular vote in 1800 is "not available". Yet in 2002, Michael Dubin published United States Presidential Elections 1788-1860. According to that book, in 1800 the national popular vote was: Jefferson 41,516; Adams, 25,748. Since Jefferson was actually elected in that election, 1800 is not an example of the electoral college electing the candidate who placed second in the popular vote.
Edwardís claim that Nixon received more popular votes than Kennedy in 1960 is based on the theory that Kennedy "really" only received 147,295 votes in Alabama.
Actually, Kennedy received 318,303 votes in Alabama in 1960. The only reason Edwards even tries to argue that Kennedy received fewer voters, is that the Democratic slate of presidential electors in 1960 was composed of five Democrats who promised to vote for Kennedy in the electoral college if they were elected, and six Democrats who said they wouldnít vote for him.
At the time, Alabama listed all candidates for presidential elector on the ballot, with a check box on the ballot next to the name of each candidate for presidential elector. Voters werenít forced to vote for just one partyís candidates for elector; they could pick and choose various elector candidates from amongst all five parties that were on the ballot in 1960. The highest vote-getting Kennedy elector received 318,303 votes; the highest anti-Kennedy Democrat received 324,050 votes. The entire Democratic slate was elected; Nixon electors only received between 237,981 and 230,951 votes. In the electoral college, the five Democrats who had said they would vote for Kennedy kept their word. The other six Democrats also kept their word that they wouldnít vote for Kennedy. They voted for Democratic U.S. Senator Harry Byrd of Virginia, to show their displeasure with proposed civil rights legislation.
Edwards arrives at the artificial total of 147,295 votes for Kennedy by multiplying five-elevenths times 324,050. The falsity of such a formula can easily be shown in this way. Imagine that a list of all the 318,303 voters who voted for a Kennedy elector exists somewhere (obviously, since the U.S. has a secret ballot, no one could ever possess such a list). While visualizing this list of 318,303 voters who voted for an elector pledged to Kennedy, it is clearly absurd to somehow imagine that only 147,295 people really "voted for Kennedy".
Other errors: the book says that in Arizona, candidates for presidential elector are chosen in party primaries. This has not been true since 1985. The book says that in Louisiana, Mississippi and South Carolina, voters can still vote for separate candidates for presidential elector. But this has not been true in Louisiana since 1976, and has not been true in the other two states rsince 1980.
The book makes a common error when it says Abraham Lincoln was "not on the ballot" in ten states in 1860. Actually, back in 1860, "on the ballot" had no meaning. Private ballots were legal (in fact, no other ballots existed; parties printed their own ballots and distributed them to whomever wanted one). Lincoln didnít receive any votes in ten southern states, not because he was kept off any ballot, but because his campaign didnít nominate any presidential elector candidates in those states.
Most writings in support of the electoral college claim that the electoral college hurts minor parties, and treats this as a virtue. Edwards tries to turn the tables on his opponents by claiming that the electoral college actually helps minor parties and independent presidential candidates. His arguments are quite strong. He points out that nowadays, it is common knowledge that over half the states are not competitive in presidential elections. Therefore, the voters are free to vote for minor party or independent presidential candidates without being afraid of the "wasted vote" symdrome. He also points out that under the Electoral College, minor party and independent presidential candidates still show quite a bit of support every so often.
Unfortunately, he seems to accept the notion that strong minor party and independent presidential candidates "damage the two-party system". A case can be made that such candidates help keep the two-party system healthy, by guarding against the tendency of one major party to become permanently stronger than the other one. Edwards, like many other authors, glibly discusses "the two-party system" without defining it first.
The normal 2006 petitioning chart is omitted from this issue of Ballot Access News. During the last month, the Libertarian Party has started petitioning in Arkansas and New Mexico; the Green Party has started in Arizona, Arkansas, and Montana; and the Constitution Party has started in Hawaii.
California holds a special election in the 48th congressional district on October 4. Although 17 candidates are on the primary ballot, only four of them have raised enough money to file a campaign finance report. For the September 22 filing, the leading Democrat, Steve Young, had raised $62,493. The Constitution Party candidate, Jim Gilchrist, had raised $111,731. Among the Republicans, State Senator John Campbell had $795,019 and Assemblyman Marilyn Brewer had $577,259.
California: held a special election for Assembly, 53rd district, on September 13. The vote: Democratic 59.5%; Republican 38.5%; Peace & Freedom 2.0%. In November 2004 the vote had been Democratic 50.5%; Republican 42.2%; Libertarian 4.7%; Peace & Freedom 2.6%.
Pennsylvania: held a special election for state Representative, 200th district, on September 13. The vote: Democratic 76.4%; Green 15.9%; Republican 7.7%. In November 2004 there had been only one candidate, a Democrat.
On September 13, both Minneapolis and St. Paul held Mayoral elections. In Minneapolis, Elizabeth Dickinson polled 19.5% in an 8-candidate race, placing third. In St. Paul, Farheen Hakeem polled 13.8% in a twelve-candidate race, also placing third.
On November 18-20, the Veterans Party will hold its first national conference, in Tampa, Florida. For more information, see VeteransParty.us.
The League of Women Voters of New Jersey is sponsoring a televised gubernatorial debate on October 18 (New Jersey and Virginia are holding gubernatorial elections this November). The League has invited four candidates, and all say they will attend: U.S. Senator Jon Corzine (Democratic); Doug Forrester (Republican); Jeffrey Pawlowski (Libertarian); and Hector Castillo (independent). Castilloís ballot slogan is "Education Not Corruption".
Each state League has its own traditional policy on whether to invite any minor party or independent candidates into its debates. The New Jersey League has historically not done so. This year, however, Pawlowski and Castillo were invited because they have each raised over $300,000.
Before the League set up its debates, it had looked as though there would be no 4-way debate. A New Jersey Public TV station (NJN) sponsored a debate and invited only Corzine and Forrester. Pawlowski sued to gain entry into this debate, but a judge denied injunctive relief on the grounds that Pawlowski would not suffer irreparable harm if he were excluded.
Then, the New Jersey State Campaign Finance office, known as NJ ELEC, set out to sponsor a debate. New Jersey campaign finance laws require NJ ELEC to sponsor debates and invite anyone who had raised $300,000. NJ ELEC then said that it would only invite Pawlowski and Castillo to debate, since Corzine and Forrester had already debated each other in the Public TV debate.
ERRATA: the Sep. 1 B.A.N. story on the Alaska Supreme Court blanket primary decision said that the Democratic, Libertarian and Alaskan Independence Party had joined the Green lawsuit. They supported it, but didnít join it.
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